U.S. Court of Appeals for the Second Circuit
United States v. VanHoesen
August 24, 2026
Summary
The Second Circuit affirmed the eight-year term of supervised release imposed when the district court resentenced VanHoesen under § 404(b) of the First Step Act, holding that a resentencing court lacks authority to reduce a congressionally mandated supervised release minimum by invoking § 401(a)'s nonretroactive changes to the statutory trigger or the Sentencing Guidelines amendments implementing them. Although the district court mistakenly believed intervening Supreme Court precedent on plenary First Step Act resentencing discretion let it consider those changes in calculating the statutory minimum, the panel concluded that precedent reaches only discretionary sentencing decisions outside statutory and constitutional limits. Because the district court actually imposed the applicable mandatory minimum despite its legal error, the error was harmless and no remand was required. Reviewing for plain error, the panel affirmed the judgment in full.